Can one evidence set satisfy SOC 2, ISO 27001 and CMMC at once?
No, a single evidence set cannot fully satisfy SOC 2, ISO 27001, and CMMC simultaneously due to their distinct scopes, objectives, and reporting requirements. While significant control overlap permits substantial evidence reuse across these frameworks, each mandates specific documentation, testing, and reporting unique to its compliance objectives. Organisations must supplement common evidence with framework-specific artefacts to achieve full compliance for each standard.
Practitioners should leverage a unified control framework or mapping exercise to identify common controls and practices across SOC 2, ISO 27001, and CMMC. This approach facilitates the collection of 'common denominator' evidence, such as access control logs, incident response plans, and risk assessments, which can support multiple compliance efforts. For instance, evidence demonstrating robust logical access controls is relevant to SOC 2's Security criteria, ISO 27001's A.9 (Access Control), and CMMC's AC (Access Control) domain. This strategic alignment reduces redundant effort and streamlines audit preparation, optimising resource allocation.
However, organisations frequently err by assuming generic evidence suffices for all frameworks. SOC 2 requires an auditor's opinion on the operating effectiveness of controls against Trust Services Criteria, often necessitating specific testing evidence. ISO 27001 demands a certified Information Security Management System (ISMS), requiring evidence of management review, internal audits, and continual improvement processes. CMMC, particularly at higher levels, mandates specific documentation of processes, policies, and plans directly linked to NIST SP 800-171 practices, alongside evidence of their implementation and institutionalisation. Each framework's unique reporting format and assurance requirements necessitate tailored evidence and distinct assessment processes.
Sources
- AICPA Trust Services Criteria for Security, Availability, Processing Integrity, Confidentiality, and Privacy (TSP section 100)
- ISO/IEC 27001:2022, Information security, cybersecurity and privacy protection — Information security management systems — Requirements (Clause 4-10, Annex A)
- Cybersecurity Maturity Model Certification (CMMC) Model v2.0, Level 2 (Practices aligned with NIST SP 800-171)